Privacy Policy

Last Updated: October 2019

Pomo One Marketing, Inc., dba ArrowShade (“we”, “us”, “our” or “ArrowShade”) is a wholly-owned economic development arm of the Habematolel Pomo of Upper Lake (“the Tribe), a federally recognized Indian Tribe, and is incorporated under the laws of the Tribe. Its activities are governed by this policy. A copy of the Tribe’s ordinance may be found here.

ArrowShade is committed to maintaining your confidence and trust as it relates to the privacy and usage of your information. Below details the type of information we may collect from you, and our practices for collecting, using, maintaining, protecting, and disclosing information when you visit this website (the “Website”) and all websites owned and operated by ArrowShade on which this privacy policy is displayed (collectively the “ArrowShade Business”). The ArrowShade Business includes but is not necessarily limited to the business conducted on the website and through entities, divisions, or brands associated with ArrowShade.

  1. Information We Collect. We may collect “nonpublic personal information” (NPI) to offer personal loans, financially-related products and/or other offerings that you seek by way of application or use of the website. NPI is any “personally identifiable financial information” collected about an individual in connection with providing a financial product or service, unless that information is otherwise “publicly available.”  Any collection of NPI is performed with your consent. We may collect information from other sources, including entities that are affiliated with us by common ownership and other third parties, and may combine it with information we collect about you.

Nonpublic Personal Information is:

  • Any information an individual may give to get a financial product or service, such as name, address, income, Social Security Number
  • Any information given from an individual for a financial transaction such as account numbers, payment history, loan or deposit balances and credit or debit card purchases
  • Any information in connection with providing a financial product or service such as court records or consumer reports

Nonpublic Personal Information is not:

  • Information that we have a reasonable basis to believe is lawfully made “publicly available” such as telephone numbers listed in the public directory, public government records and information that is in widely distributed media such as websites and newspapers


2. How We Use Your Information. We may use the information that we collect about you to (i) deliver the products and services you requested; (ii) inform you of products and services offered by us, our affiliates and/or partners; (iii)  aggregate information for various purposes like market analysis and reporting; (iv) display advertising tailored to your interests or background; (v) improve systems, service and website; (vi)  for everyday business purposes.

3. What Information We Share. The personal information you submit to the Website on our application will be shared with the entities and for the purposes defined below. This includes your name, contact information, Social Security number, or anything else you provide on the application. You are submitting your personal information in order to affect a financial transaction, on your request; therefore you are unable to opt-out of this sharing. All sharing is done as permitted by law.

4. Who We Share Your Information With. ArrowShade may disclose personal information that we collect, or you provide, to the following:

Affiliates. We may share information with affiliated entities for everyday business purposes or to offer products and services to you.

Third Parties.  We may share information with third parties. Use of your information will be subject to those third party’s separate privacy policies.

Service Providers. We may share information with third parties who perform services on our behalf.

Business Transfers. Information about you may be disclosed as part of any merger, acquisition, sale of company assets or transition of service to another provider. In the unlikely event of an insolvency, bankruptcy or receivership, information may also be transferred as a business asset.

Other Situations. We may also use or disclose your information at our discretion for the following: (i) to comply with the law or respond to lawful requests or legal process; (ii) to protect our rights or property as well as the rights and property of our agents and others including to enforce our agreements, policies and terms of use; (iii) when responding to emergencies; (iv) to initiate, render, bill, and collect for services.

5. Data Retention and Security.ArrowShade uses reasonable efforts to protect the security of your personally identifiable information. We maintain a variety of physical, electronic, and procedural safeguards such as: restricting access to personally identifiable information, requiring a secure login to access data, and data protection by way of secured repositories. These safeguards help protect your information from loss, misuse, unauthorized access, or alteration. ArrowShade shall not be liable for unauthorized disclosure of personal information due to no fault of ArrowShade including, but not limited to, errors in transmission and unauthorized acts of third parties.

6. Third-Party Links. Advertisements on this website may contain links to third party websites. The information practices of these third parties are not covered by this privacy policy and we do not have access to, or control over, the information they may collect, therefore you should review the privacy policy posted on any third-party website thoroughly before disclosing any personal information.

7. Consent to Communicate. When you submit your personal information to this website, you are providing your express consent to be contacted by us. You may request to be added to our do-not-contact registry by sending an email to We still may contact you for non-promotional purposes. If you disable cookies on your Internet browser, you may stop some collection and use of data when you visit our websites.

8. Modifications or Amendments. ArrowShade has the discretion to change this policy at any time.  If a change occurs, the revised date will be listed at the top of this page. Continued use of this website after any such change signifies and confirms acceptance of any changes or amendments to this policy.

9. Children Under the Age of 13.  ArrowShade does not knowingly collect or use personal information from individuals under 13 years of age. You must be 18 to subscribe to our services.

10. Contact Us. If you have any questions or comments regarding this policy or our practices, please contact us at